While all Performance Standards are applicable to this investment, IFCs environmental and social due diligence indicates that the investment will have impacts which must be managed in a manner consistent with the following Performance Standards. If IFCs investment proceeds, IFC will periodically review the the project’s ongoing compliance with the Performance Standards

PS 1 – Assessment and Management of Environmental and Social Risks and Impacts
PS 2 - Labor and working conditions
PS 3 - Resource Efficiency and Pollution Prevention
PS 4 – Community Health, Safety and Security
PS 6 – Biodiversity Conservation and Sustainable Management of Living Natural Resources

If IFC’s investment proceeds, IFC will periodically review the the project’s ongoing compliance with the Performance Standards

Impacts related to PS5, Land Acquisition and Involuntary Resettlement, PS7: Indigenous Peoples and PS8: Cultural Heritage were not found of direct relevance due the nature of the project to finance working capital needs of existing operations. Astarta’s ongoing operations are within existing locations, found within consolidated industrial zoned areas and also on existing farming land with no conversion of natural/critical habitats; there is no presence of indigenous peoples or cultural artifacts within either of these land uses.

This is a category B project according to IFC’s Policy on Environmental and Social Sustainability because a limited number of specific environmental and social impacts may result that can be avoided or mitigated by adhering to generally recognized performance standards, guidelines or design criteria as is described in the following sections.

Specific key environmental and social issues reviewed include: (i) client’s corporate environmental and social management capacity to operate in a manner consistent with IFC Performance Standards; (ii) working conditions for employees during construction activities; (iii) occupational health and safety (OHS); (iv) efficient use of energy and water; (v) wastewater management; (vi) structural, and life and fire safety (L&FS); (vii) management of armed security personnel; and (viii) EHS management in construction.

IFC's appraisal considered the environmental and social management planning process and documentation for the project and gaps, if any, between these and IFCs requirements. Where necessary, corrective measures, intended to close these gaps within a reasonable period of time, are summarized in the paragraphs that follow and (if applicable) in an agreed Environmental and Social Action Plan (ESAP). Through the implementation of these measures, the project is expected to be designed and operated in accordance with Performance Standards objectives.

In 2015, Grupo Roble obtained ISO 9001 certification, which standardizes
processes related to customer service, housekeeping, maintenance, and physical
security in shopping centers. At present, 9 out of the 19 shopping centers
owned by Grupo Roble are included in the certification, but all shopping
centers have adopted it. Out of the three shopping centers that will be
remodeled or expanded under this loan, only Multiplaza Tegucigalpa, Honduras,
is ISO 9001 certified. Metrocentro Managua, Nicaragua, and Metrocentro Santa
Ana, El Salvador, will be independently audited in 2017.

Beyond the current scope of ISO 9001, Grupo Roble has also implemented a
corporate management system for human resources, and is also in the process of
standardizing its occupational health and safety (OHS) practices. All
documentation related to Grupo Roble’s management systems is accessible through
the company’s intranet.

Policy: Grupo Poma has developed a corporate code of conduct that is shared
with all employees at the time of hiring. The code of conduct includes the
company’s commitment to comply with national labor laws and to provide benefits
to employees beyond what is legally required. Additionally, the code of conduct
states Grupo Poma’s commitment to implement practices to minimize or avoid
negative environmental impacts from its operations.

Identification of Risks and Impacts: Various risk assessment methodologies are
used to identify potential environmental and social risks. Job hazard analyses
are regularly conducted in the shopping centers, and OHS and L&FS inspections
regularly take place in the common and leased areas of the shopping centers.
Independent consultants are commissioned to carry out the environmental impact
assessments of new constructions as required by law.

Management Programs: As aforementioned, Grupo Roble has developed procedures
to manage human resources, OHS, L&FS, and physical security. No specific
procedures have been documented for the management of environmental aspects,
but regular environmental activities such as the recycling of some categories
of solid waste, the cleaning of grease traps, and the installation of water and
energy saving equipment do take place. OHS Coordinators develop annual work
plans, which list the schedule of inspections and trainings, and corrective
actions to be implemented. The company is also required to implement
environmental management plans (EMPs) to obtain construction and operations
permits. The implementation of the required mitigation measures included in the
EMPs are regularly inspected by the relevant authorities

Organizational Capacity and Competency: Three regional managers – human
resources, operations, and physical security – are in charge of standardizing
and improving practices among companies belonging to the group. These
positions are replicated at a country level, with the addition of occupational,
health and safety (OHS) coordinators, who report to country operations
managers. In Nicaragua, where Grupo Roble has only one shopping center, OHS
duties are the responsibility of the shopping center manager. A detailed
employee training plan is developed and implemented every year in each country.
Trainings are adapted to the targeted audience and include topics related to
human resources, customer service, OHS, L&FS, and physical security.

Emergency Preparedness and Response: Emergency plans have been developed for
all shopping centers. Emergency drills with the participation of all the
stores, the general public, and the fire department are conducted once a year
in every shopping center. Results of the exercises are analyzed to identify
and rectify deficiencies. Every shopping center has emergency brigades (i.e.
fire, first aid, evacuation) that are regularly trained by qualified
instructors. Members of the emergency brigades have been selected so that
members of all three brigades are present during hours of operation. Anchor
stores are also legally required to have their own emergency brigades. Other
aspects of emergency preparedness and response are covered under section PS4.

Monitoring and Review: Under the ISO 9001 management systems a series of
indicators have been selected to monitor compliance with procedures and their
effectiveness. In each country, new indicators can also be approved by the
country General Manager. Among key performance indicators managed at corporate
level by Grupo Poma are water and energy consumption. Among the human
resources indicators managed at corporate level are employee satisfaction and
turnover rate. OHS statistics are recorded and analyzed at country level.

Environmental management in constructions: An environmental impact assessment
(EIA) was carried out for the expansion of Metrocentro Santa Ana. The EIA and
its associated environmental management plan (EMP) was approved by the relevant
authority. The contract with EPC contractors includes the requirement to comply
with all environmental mitigation measures established in the EMPs. Among the
mitigation measures to be implemented during construction are the management of
fugitive dust (dust control water tanks were observed on site), noise, runoff,
and solid waste. For the expansion of Metrocentro Santa Ana, about 500 trees
had to be cut down; to comply with national legal requirements, Grupo Roble has
paid a compensation fee US$72,662 and will plant 5,100 trees in an area to be
determined by the relevant authority. No EIA was required for the expansion of
Metrocentro Managua.

Grupo Roble has approximately 5,000 employees. Depending on the shopping
center, about 50 to 150 workers are employed in each shopping center for
housekeeping, regular maintenance, and security. All regular workers for the
company are full-time employees; no contract labor is used for day-to-day jobs.

Human Resources Policies and Procedures: Grupo Roble has documented policies
and procedures for recruitment, selection, hiring, induction and training,
promotions, non-salary benefits, and termination. Corporate HR policies and
procedures are uploaded in the company’s intranet and have been adopted by all
country offices.

Working Conditions and Terms of Employment: All ILO Fundamental Conventions
have been ratified and are in force in El Salvador, Honduras and Nicaragua.
Internal Work Regulations – dutifully approved by the Ministry of Labor of each
country – are consistent with Performance Standard 2 requirements and inform
employees about their rights and responsibilities, including work schedules,
overtime arrangements and overtime pay, rest days, holidays, provisions on
non-discrimination, and disciplinary procedures. Working relationship is
defined in a written contract between employee and employer, which is explained
to and signed by the employee. The contract makes reference to the internal
work regulations but also covers individual arrangements, such as: functions,
work schedule, and salary. Salary levels meet legal minima in the countries
in which Grupo Roble operates. Grupo Roble also offers a wide range of
non-salary benefits which exceed country requirements, such as, life insurance,
support in the event of bereavement, and bonuses for Christmas, wedding,
maternity, and college graduation. The company also provides basic medical
care through access to clinics and has an optional employee savings fund.
Employees are informed of their rights and responsibilities at the time of
hiring and a hard copy of Grupo Poma’s code of conduct, the internal work
regulations, and the contract is provided to them. Payments are scheduled
every 15 or 30 days and a printed payroll is given to each employee. Payrolls
list the accrued income, the payment for additional overtime (beyond the
overtime already established in the contract), and deductions, such as income
taxes, social security, and others. As part of the ESAP, ISCH’s subsidiaries
receiving finance under this facility will also include the amount of overtime
hours in the payrolls (ESAP action nr.1). ISCH’s subsidiaries receiving
finance under this facility will also analyze working hours effectively worked
by its employees – in particular by physical security – to ensure statutory
regulations on the limitation of standard and total working time are met.
Monitoring results, with the identification of eventual non-compliances and
corrective measures will be reported to IFC in the Annual Monitoring Report.

Workers’ Organization: Grupo Roble indicates that it does not restrict workers’
rights to form workers’ organizations. No workers’ organizations exist in any
of the countries where the company operates.

Grievance Mechanism: The code of conduct mentions that employees should
approach the Human Resources department to present complaints in the first
instance, and that the department has the responsibility to dutifully
investigate complaints and take the necessary disciplinary actions. Human
Resources department staff make monthly pre-announced visits to the shopping
centers, and are available for discussion with staff. Complaints related to
harassment and discrimination are managed confidentially and thoroughly
investigated. As part of the ESAP, ISCH’s subsidiaries receiving finance under
this facility will document a complaint management and resolution procedure,
which reflects the practices currently in place. The procedure will ensure that
timely feedback is provided to those concerned and that there will be no
retribution against those who present a complaint. ISCH’s subsidiaries
receiving finance under this facility will inform workers of the grievance
mechanism at the time of recruitment, and will maintain and analyze records of
complaints presented by employees (ESAP action nr.2). Another mean that
employees have to make their views known are the annual organizational climate
surveys. These surveys have high response rates, and overall favorable
responses. Complaints are mostly related to unfair treatment form supervisors.
To tackle this issue, Grupo Roble is proactively engaging supervisors in
leadership trainings, and increasing their role as trainers of workers under
their responsibility. An additional indicator reflecting a positive work
environment in Grupo Roble is the low employee turnover rate, which has
averaged 11 percent in the last three years in Honduras and El Salvador.
Employee turnover in Nicaragua is higher as legal compensation benefits in the
case of dismissal or resignation are not accrued past the fifth year of
employment. To address this, the company has implemented additional benefits
with positive results, employee turnover decreased from 52 percent in 2013 to
36 percent in 2015.

Non-discrimination and Equal Opportunity: Grupo Roble has a policy of
non-discrimination on the basis of any characteristic not related to a person’s
ability to meet job requirements. Recruitment and advancement is solely merit
based, and the company has an explicit policy to promote internal recruitment.
The company has also an “equal pay for equal job policy”. The percentage of
women employed in the areas of housekeeping, maintenance, and security is about
10 to 20 percent, while women representation in administrative areas ranges
from 35 to 70 percent. According to the company, the low percentage of women
employed in the areas of housekeeping, maintenance, and security is due to the
low number of women applying to those types of positions due to the strenuous
characteristics of the job.

Retrenchment: No staff optimization is planned as a result of this IFC’s
investment. About 56 direct new jobs are expected to be created as a resulted
of the programmed expansions and renovations.

Protecting the Work Force: Grupo Roble verifies the identity of all potential
employees and does not employ minors or any type of involuntary or compulsory
labor.

Workers Engaged by Third Parties: Grupo Roble ensures that all service
providers – such as for construction, remodeling and extraordinary maintenance
– are reputable companies. As part of the ESAP, ISCH’s subsidiaries receiving
finance under this facility will include in the contracts with service
providers contractual provisions on the prohibition of child labor and forced
labor, and the obligation of contractors to guarantee that their workers have
been hired legally and receive wages and benefits as established by law;
non-compliance by contractors will be motive for the anticipated termination of
the contract (ESAP action nr.3).

Occupational Health and Safety: OHS Coordinators are present in Honduras and El
Salvador; in Nicaragua, OHS responsibilities are assumed by the Manager of the
shopping center. OHS management is not within the scope of the ISO 9001
certification; however, OHS Coordinators meet annually to share good practices
and there has been an increasing standardization of procedures in the last
three years. Job hazard analyses, including the identification of preventative
measures, are now regularly performed for each job position. OHS annual working
plans are also established in all shopping centers.

Joint worker-management OHS committees are elected in all shopping centers.
Duties of OHS committees vary among countries; not in all countries OHS
committees participate in the identification of workplace hazards, provide
feedback on the development of control programs, and participate in accident
investigations when required or appropriate. As part of the ESAP, ISCH’s
subsidiaries receiving finance under this facility will standardize, document,
and communicate the duties of OHS committees in each country, and ensure they
have the capacity and resources to effectively perform their duties. (ESAP
action nr.4). Beyond the duties defined by law, OHS committees have been tasked
with the inspection of life and fire safety (L&FS) compliance by store tenants.
For that purpose, OHS Coordinators have developed standardized inspection
checklists that include aspects such as: the state of electrical installations,
fire detection and control equipment, means of egress, and awareness of
emergency response procedures. If deficiencies are observed, OHS Coordinators
and shopping center Managers take corrective actions. Further details on L&FS
are provided under Performance Standard 4.

Safe work permit systems for employees and contractors have been implemented in
all shopping centers. Commencement of activities that include work at heights,
in rooftops, and in confined spaces have to be previously approved by the OHS
Coordinators or the shopping center Manager. Shopping centers maintain records
of accidents and incidents affecting workers, contractors, and clients.
Root-cause analysis of occupational accidents and incidents is performed to
prevent reoccurrence. Lost time injury frequency rate (LTIFR, injuries per
million hours worked) in 2014 and 2015, was below industry average in
Metrocentro Santa Ana and Multiplaza Tegucipalpa, and above industry average in
Metrocentro Managua. Lost time accidents and corrective measures to prevent
reoccurrence will be reported to IFC in the Annual Monitoring Report.

Occupational Health and Safety in Constructions: As part of this loan, IFC will
finance the expansion of Metrocentro Santa Ana, in El Salvador, and Metrocentro
Managua, in Nicaragua. OHS management during construction is a contractual
requirement of Grupo Roble, and both EPC contractors have established site
specific OHS management plans and have on-site OHS Supervisors.

At Metrocentro Santa Ana, terracing, filling and soil compaction works are
almost completed, and construction is planned to be finished by November 2017.
Filling and soil compaction is almost completed at Metrocentro Managua as well,
and construction is programmed to be finished by June 2017. In both
construction sites, EPC Contractors will manage an average of 6 to 8
subcontractors, and about 200 to 250 workers will be on site during peak time
activities. Consistent with IFC requirements related to workers engaged by
third parties, access to construction sites is restricted and workers are not
allowed to enter the construction sites if they have not received OHS induction
training and are not wearing the required personal protective equipment.
Safety toolbox talks are also provided at the beginning of each shift, twice or
three times a week. Both companies provide regular reports on the
implementation of OHS activities and accidentability rates. OHS oversight of
construction activities at both sites is ensured by the civil engineers of
Grupo Roble in charge of the constructions, which are permanently on-site. In
El Salvador, the civil engineer is also supported by the OHS Coordinator, who
visits Metrocentro Santa Ana regularly. At the time of the site appraisal
visit, good housekeeping practices were observed on both construction sites.

Base camps have been established both in Metrocentro Santa Ana and Metrocentro
Managua; portable bathrooms, changing rooms, cafeterias, and potable water
points are been installed. As part of the ESAP, once soil compaction is
completed, Metrocentro, S.A. de C.V. in El Salvador and Metrocentro, S.A. in
Nicaragua, will ensure that EPC contractors install and adequately maintain
portable bathrooms and points with potable water throughout the site – and not
only at the base camp – to facilitate access by construction workers (ESAP
action nr.5).

Water consumption and liquid effluents: Water is used in the shopping centers
for domestic uses in food court tenants’ kitchens, for general washing and in
some cases for irrigation of garden areas. Water used by tenants is submetered
and consumption not further controlled by Grupo Roble. In common areas, Grupo
Roble has installed water-saving measures such as automatic faucets and
waterless urinals.

Liquid effluents in Metrocentro Managua (Nicaragua) are discharged into the
municipal sewage system and treated in the wastewater treatment plant of
Managua, previous to their final discharge into the Lake Xolotlan. The
wastewater treatment plant of Managua was inaugurated in 2009 and has an
adequate capacity to receive and treat Metrocentro's effluents. Liquid
effluents in Multiplaza Tegucigalpa (Honduras) are treated by an on-site
wastewater treatment plant with an installed capacity of 150 m3/day, which is
operated and maintained by a contractor. Physico-chemical and microbiological
analysis of treated effluents are performed every six months to ensure they
meet national standards for discharge of effluents into surface waters. At
present, Metrocentro Santa Ana (El Salvador) discharges its untreated
wastewater to the municipal sewerage, which collects but does not treat the
wastewater before discharging it into surface waters. To comply with IFC
requirements, as part of the ESAP, Metrocentro, S.A. de C.V., El Salvador, will
apply in due time for a permit to build and operate a wastewater treatment
plant to treat all liquid effluents from Metroplaza Santa Ana to meet national
standards for discharge of effluents into surface waters (ESAP action nr.6).
The company shall procure and build the WWT plant within 180 days after
obtaining the permit (ESAP action nr.7 and 8). Grease traps are located in all
shopping centers at each food court’s kitchen and in the exterior. Tenants are
required to clean grease traps daily, and authorized service providers are used
to regularly clean grease traps outside the shopping centers.

Energy efficiency: The estimated project-related Greenhouse Gases emissions
are about 10,000 tons of CO2 equivalent annually. Forced ventilation is
provided in food courts, but otherwise only natural ventilation is used in
common areas. Store air conditioning is done by individual AC units with
direct expansion (DX) located in the rooftops of each shopping center. AC
units are installed and maintained by Grupo Roble, but energy consumption
related to its use is the direct responsibility of each tenant. Grupo Roble is
analyzing the feasibility of replacing all 4,000 AC units installed throughout
their shopping centers with more energy efficient equipment. At present,
tenants are not formally required to install energy-saving lighting, but
shopping centers do put in place awareness campaigns and have requested tenants
to replace all neon signs with LED technology. Water and energy consumption are
key performance indicators managed at corporate level by Grupo Poma. Water and
energy consumption for common areas, and where feasible for leased areas, of
buildings financed by this facility, will be monitored and reported to IFC in
the Annual Monitoring Report.

Solid Waste Management: Grupo Roble provides solid waste management services to
its clients. In El Salvador and Honduras, paper and cardboard are recycled.
In Nicaragua, plastic is also recycled. Non-recyclable wastes are removed from
the shopping centers by authorized contractors or the municipality who
transfers and disposes the waste at government authorized landfill sites.

Hazardous Materials: All cleaning and pest control materials are appropriately
stored in locked rooms and with secondary containment.

Pesticide Use and Management: Grupo Roble is responsible for disinfection and
pest control in common areas; while each individual tenant is responsible for
each own store/kitchen. As part of the ESAP, ISCH’s subsidiaries receiving
finance under this facility will review its operations manuals for the food
court and other commercial areas to include the prohibition of using products
that fall in WHO Recommended Classification of Pesticides by Hazard Class Ia
(extremely hazardous) or Ib (highly hazardous) (ESAP action nr.9). The only
exception will be the use of rodent traps where the bait is not going to be
accessible to humans.

Infrastructure and Equipment Design and Safety / Life and Fire Safety (L&FS):
The structural and L&FS designs of both extensions - Metrocentro Santa Ana (El
Salvador) and Metrocentro Managua (Nicaragua) - have been prepared by qualified
professionals based on locally or internationally recognized standards, and
have been approved by the relevant authorities. El Salvador and Honduras are
countries at high risk of seismic activity. Therefore, expansions have been
designed in accordance with up-to-date locally or internationally recognized
seismic building codes. Once the expansions are completed, as part of the
ESAP, Metrocentro, S.A. de C.V. in El Salvador and Metrocentro, S.A. in
Nicaragua, will conduct post-construction inspections by suitably qualified
professionals to certify that constructions have followed the approved L&FS and
structural designs; and L&FS systems were properly tested and commissioned.
(ESAP action nr.10).

Shopping centers visited during the appraisal have fire detection, alarm and
suppression systems consisting of extinguishers, fire hoses and sprinklers
(Metrocentro Santa Ana phase 1 has no sprinkler system). Connections to the
sprinkler system arrive to every store and it is responsibility of each tenant
to install the sprinklers inside their stores. All shopping centers have fire
pumps and emergency water tanks. The fire emergency panels are located in the
CCTV rooms and are monitored 24/7 by security personnel. Established
communication protocols with security personnel stationed in the shopping
center exist in case of an alarm. Lease contracts signed by tenants include
provisions to comply with L&FS guidelines listed in the operations manuals for
the food court and other commercial areas. As mentioned in section PS 2, OHS
committees have been tasked with the inspection of L&FS compliance by tenants.
Stores are inspected every two months and kitchens in the food court are
inspected every month, for which appropriate checklists have been developed.
In Honduras, inspection checklists have been also developed to inspect the
correct operation of emergency lighting and evacuation routes. In 2015, the
inspection of Multiplaza Tegucigalpa by the fire department identified the need
to increase the size and quantity of the evacuation signage. Accordingly, the
shopping center is implementing new emergency and evacuation signage. Lessons
learned will be shared and replicated by other shopping centers of the group.

As part of the ESAP, ISCH will retain a qualified professional to support
corporate and in-country Managers in the standardization and consistent
adoption of a corporate L&FS system, including the revision of procedures,
inspection checklists, and training programs at all levels of the company. The
responsibilities of the L&FS consultant shall also include life safety audits
based on the NFPA Life Safety Code 101 of the buildings that will receive
finance under this facility, once its expansion or renovation has concluded
(ESAP action nr.11). Corrective actions will be implemented according to a
timeline agreed with IFC (ESAP action nr.12). As during the visit it was noted
that some of the fire panels showed a number of activated alarms that had not
been reset, Grupo Roble’s L&FS system will include a procedure to ensure that
whenever an alarm is activated, whether due to a real emergency or a false
alarm, the alarm is reset without delays by a competent person.

Security Personnel: Grupo Roble employs armed security guards at the shopping
centers. Security guards are direct employees of Grupo Roble and they are
subject to a rigorous selection process that was revised and improved in 2014.
The process includes background checks and psychometric tests among other
measures. The company prefers to employ persons who are not familiar with guns
and to train them. Grupo Roble has a Regional Security Manager and Security
Chiefs in each country, which are responsible of the implementation of security
procedures, and security personnel training and supervision. Security guards
receive regular training on customer service, legal principles and rules of
self-defense, and use of baton and firearms. In Nicaragua, security personnel
also receives regular training on self-defense techniques without the use of
weapons. Security personnel is also trained in communication protocols and
evacuation procedures in case of an emergency. Guns used by security personnel
are the property of the company, they can only be carried in their apposite
pouch, and remain on company premises at all times. Grupo Roble maintains
records of the number of days with no gunfire. In the event that security
personnel retains an alleged criminal, the company immediately informs the
police so that the police can proceed with the detention.

As part of the ESAP, ISCH will identify what are the security risks in its
shopping centers and assess if the likely response by its security personnel,
and public security forces called to intervene, is proportional to the nature
and extent of the threat. Based on this risk assessment, the company will
review its security arrangements to ensure these are guided by the principles
of proportionality and progressive use of force (ESAP action nr.13). As part of
the ESAP, shopping centers will also implement a grievance mechanism so that
tenants and visitors can report any alleged abuse by security personnel (ESAP
action nr.14)

Not applicable.

As part of ISO 9001, Grupo Roble has implemented a hotline to receive communications from its clients. At the moment, clients are defined as tenants of the shopping center and do not include visitors. Communications with visitors are managed through information desks (in some of the shopping centers) and social media (facebook). As part of the EIA for the expansion of Metrocentro Santa Ana, Affected Communities were informed and consulted on the project, and a notice on the project was published for three days in a newspaper with national circulation.

Contact Person: Carlos J.Medina
Company Name: Grupo Roble
Address: Edificio Grupo Roble, Blvd. Tutunichapa, Costado Norte Metrocentro San Salvador
Email: mailto:carlos.medina@gruporoble.com
Phone: 503.25056100

Broad Community Support is not applicable for this project

S.no	Description	Anticipated Completion Date	Status
1	Provide an operational structure	06/30/2016	Completed
2	ISCH’s subsidiaries receiving finance under this facility will include amount of overtime hours – in addition to overtime pay – in payrolls.	01/31/2017	Completed
3	ISCH’s subsidiaries receiving finance under this facility will document a complaint management and resolution procedure reflecting HR practices currently in place. The procedure shall ensure timely feedback to those concerned and no retribution against those who present a complaint. The company will inform employees of the grievance mechanism, and will maintain and analyze records of complaints.	01/31/2017	Completed
4	ISCH’s subsidiaries receiving finance under this facility will include provisions on the prohibition of child labor and forced labor, and the obligation of contractors to guarantee workers have been hired legally and receive wages and benefits as established by law in all contracts with service providers.	01/31/2017	Completed
5	ISCH’s subsidiaries receiving finance under this facility will define, document, and communicate duties of OHS committees in each country.	01/31/2017	Completed
6	Metrocentro, S.A. de C.V. in El Salvador and Metrocentro, S.A. in Nicaragua will install and adequately maintain portable bathrooms and points with potable water throughout construction sites in Metrocentro Santa Ana (El Salvador) and Metrocentro Managua (Nicaragua) to facilitate access by construction workers.	08/30/2016	Completed
7	Metrocentro, S.A. de C.V. in El Salvador will apply for a permit to build and operate a wastewater treatment plant to treat all liquid effluents from Metrocentro Santa Ana (El Salvador). If after twelve months the permit has not been issued, the company will submit a letter from the permitting authority with an update of when the permit is expected to be issued.	01/31/2018	Cancelled
8	Metrocentro, S.A. de C.V. in El Salvador will sign contract with technology provider to build a wastewater treatment plant with adequate capacity to treat all liquid effluents discharged from Metrocentro Santa Ana (El Salvador) to meet national standards of discharge into surface waters.	03/31/2019	Cancelled
9	Metrocentro, S.A. de C.V. in El Salvador will build and operate a wastewater treatment plant to treat all liquid effluents discharged from Metrocentro Santa Ana (El Salvador) to meet national standards of discharge into surface waters.	07/31/2019	Cancelled
10	ISCH’s subsidiaries receiving finance under this facility will include the prohibition of using products that fall in WHO Recommended Classification of Pesticides by Hazard Class Ia (extremely hazardous) or Ib (highly hazardous) in the operations manuals for food court and other commercial areas.	01/31/2017	Completed
11	Metrocentro, S.A. de C.V. in El Salvador and Metrocentro, S.A. in Nicaragua will conduct post-construction inspections of structural features by suitably qualified professionals to certify that expansions of Metrocentro Santa Ana (El Salvador) and Metrocentro Managua (Nicaragua) have followed the approved Life and Fire Safety (L&FS) and structural designs; and L&FS were properly tested and commissioned.	01/31/2018	Completed
12	ISCH will retain a qualified professional to support the consistent adoption of a corporate L&FS system, including the revision of procedures, inspection checklists, and training programs. The responsibilities of the L&FS consultant shall also include life safety audits based on the NFPA Life Safety Code 101 of the buildings financed under this facility once the expansion or renovation concluded.	11/30/2016	Completed
13	ISCH’s subsidiaries receiving finance under this facility will develop corrective action plans based on the findings of the life safety audits referenced in ESAP action nr.11, in a form and substance satisfactory to IFC.	02/28/2018	Completed
14	ISCH subsidiaries receiving finance under this facility will review current security arrangements based on the results of a security risk assessment to ensure these are guided by the principles of proportionality and progressive use of force.	01/31/2017	Completed
15	ISCH subsidiaries receiving finance under this facility will implement a grievance mechanism so that tenants and visitors can report any alleged abuse by security personnel.	01/31/2017	Completed